IRS official Lois Lerner asserted her constitutional right against self-incrimination before a House committee last May. / Chip Somodevilla, Getty Images

by David Jackson and Catalina Camia, USA TODAY

by David Jackson and Catalina Camia, USA TODAY

WASHINGTON - Congress often gets frustrated when witnesses invoke their Fifth Amendment rights against self-incrimination under the U.S. Constitution - and both groups have had plenty of experience with it.

Internal Revenue Service official Lois Lerner is only the latest government official to "take the Fifth" rather than testify before Congress.

During President Obama's administration, the Fifth Amendment has been cited during probes of the Solyndra energy loan and the General Services Administration, just as it was in congressional investigations during the presidencies of George W. Bush and Bill Clinton.

The use - and misuse - of the Fifth Amendment was especially prevalent during the investigations of alleged communists during the early 1950s. Sen. Joseph McCarthy, R-Wis., and his supporters denounced those who declined to testify as "Fifth Amendment communists."

Many major congressional investigations have featured at least talk of taking the Fifth, especially in recent years when one party held the White House and the other prevailed in Congress.

During the Bill Clinton administration, former Justice Department official and Clinton lawyer Webster Hubbell declined to testify or produce documents on claims stemming from the Whitewater investigation. In 2000, a CIA official cited the Fifth Amendment during an investigation of computer security lapses.

The George W. Bush administration saw an invocation of the Fifth Amendment during a congressional review of the dismissal of several U.S. attorneys.

In 2007, Justice Department official Monica Goodling refused to answer questions about the firing of federal prosecutors. Goodling, senior counsel to then-attorney general Alberto Gonzales, was subpoenaed to appear before the Senate Judiciary Committee about the firing of eight U.S. attorneys.

"The potential for legal jeopardy for Ms. Goodling from even her most truthful and accurate testimony under these circumstances is very real," Goodling's lawyer, John Dowd, told the Associated Press at the time.

During the Obama years, executives with Solyndra took the Fifth during a 2011 investigation into a federal loan for the California energy company that went bankrupt.

Last year, General Services Administration official Jeff Neely took the Fifth when testifying before the House Oversight Committee, the same panel that Lerner appeared before on Wednesday. Neely was the official who organized the 2010 conference in Las Vegas that cost taxpayers thousands of dollars.

Of course, you don't have to be a public official to take the Fifth.

Tareq and Michaele Salahi, who crashed a 2009 State Dinner at the White House, invoked their Fifth Amendment rights when they appeared before the House Homeland Security Committee in 2010.

The committee wanted to know how the Virginia couple, who have since split up, got past the Secret Service at the dinner honoring Indian Prime Minister Manmohan Singh.

St. Louis Cardinals slugger Mark McGwire repeatedly invoked his Fifth Amendment rights before the House government reform committee in March 2005 that was investigating the use of steroids in baseball.

McGwire, who broke the single-season home run record in 1998, said at the time, "I'm not going to go into the past or talk about my past." In 2010, he admitted he used performance-enhancing drugs and did not face perjury charges.

Congress sometimes seeks to get around the Fifth Amendment invocations by granting immunity to witnesses. But this can create other legal challenges.

Oliver North received limited immunity for his 1987 congressional testimony on the Iran-Contra affair â?? and his later conviction on criminal charges stemming from that scandal was overturned when an appeals court said that testimony may have prejudiced his right to a fair trial.